Advocacy

SPFA believes in maintaining a constructive dialogue and relationship with legislative and regulatory decision-makers in order to generate policies that factor in the needs of the industry and ultimately benefit the consumer.  SPFA engages in advocacy on behalf of its members at the federal and state levels, and is predominantly focused on issues involving the environment, energy efficiency, workplace safety and health, and domestic job creation and quality installation.

Legislative, regulatory and political reporting on developments in Washington, DC, is available regularly in Craig Brightup’s column in SprayFoam Professional Magazine The Brightup Writeup, Bringing the Beltway to You. However, it’s important that we get your input as we build our program, so if you are an SPFA member and have an advocacy issue, please submit it HERE. As we continue to develop an issues agenda, following is a partial list of SPFA’s recent advocacy efforts:

FEDERAL Level

SPFA Works with Federal Interagency Task Force on SPF

Since 2009, SPFA has maintained an open working relationship with agencies comprising the Federal Interagency Task Force on SPF, notably including US Environmental Protection Agency (EPA) and US Occupational Safety and Health Administration (OSHA). The agencies, along with SPFA, have travelled to various speaking events and spoken alongside each other in a commitment to quality installations, high performance, energy and environmental stewardship, chemical and jobsite health and safety. The agencies played a vital role in providing courtesy review of SPFA’s PCP certification materials prior to release. SPFA continues to facilitate dialogue between industry and agency representatives on issues of importance, regularly hosts agency representatives at its Annual Convention and Trade Show (various agency presentations available under Convention on this website), and serves a vital role in coordination and two-way communication on issues such as the EPA Chemical Action Plan (CAP) on Isocyanates and OSHA’s National Emphasis Program (NEP) on Isocyanates, and provides feedback on various agency programs and documentation.

OSHA’s Dr. Michaels Letter to SPFA
OSHA NEP on Isocyanates
EPA Cap on Isocyanates
EPA Design for Environment (DfE) Sprayfoam Website

SPFA Supports High Performance Building Congressional Caucus Coalition (HPBCCC)

The High-Performance Buildings Caucus of the U.S. Congress was formed to heighten awareness and inform policymakers about the major impact buildings have on our health, safety and welfare and the opportunities to design, construct and operate high-performance buildings that reflect our concern for these impacts. Fundamental to these concerns include protecting life and property, developing novel building technologies, facilitating and enhancing U.S. economic competitiveness, increasing energy efficiency in the built-environment, assuring buildings have minimal climate change impacts and are able to respond to changes in the environment, and supporting the development of private sector standards, codes and guidelines that address these concerns.  SPFA, recognizing SPF’s Life-Cycle based high-performance, has been a long-time active supporter of HPBCCC initiatives, has hosted a High Performance Building Insulation Congressional briefing, and sponsors a majority of HPBCCC Congressional briefings on a variety of topics.

Residential Energy Efficiency Tax Credits Extension

SPFA worked with the Energy Efficient Tax Credit Industry Coalition, a consortium of industry and private interests to extend the Federal Residential Energy Efficiency Tax Credit.  This provision originally expired at the end of 2011.  The American Taxpayer Relief Act of 2012 retroactively renewed this tax credit effective January 1, 2012, expiring again on December 31, 2013.  Any qualified equipment installed in 2012 or 2013 is eligible for this credit. As in previous years, the cumulative maximum amount of tax credit that can be claimed by a taxpayer in all years combined is $500. If a taxpayer has already claimed a tax credit of $500 for purchases made in any previous year, they are ineligible for additional tax credits for any new equipment purchases.  SPFA worked on its members’ and their customers’ behalf to extend this important provision that reduces the investment cost of SPF, meaning customers can get to the savings even faster.

Energy Efficient Commercial Building Tax Deduction Extension (CBTD)

SPFA worked with the Commercial Building Tax Deduction Coalition to extend the Federal Commercial Building Tax Deduction several times in recent years.  Originally enacted in the Energy Policy Act of 2005, the provision allows a deduction to a taxpayer who owns, or is a lessee of, a commercial building and installs property as part of the commercial building’s interior lighting systems, heating, cooling, ventilation, and hot water systems, or building envelope.  Certification from a qualified individual using accepted software must be obtained to verify that the property installed satisfies the energy efficiency requirements of IRS Title 26 Section 179D.  A tax deduction of up to $1.80 per square foot is available for new or existing commercial buildings that save at least 50% of the heating and cooling energy of a building that meets ASHRAE Standard 90.1-2001.  Partial deductions of up to $.60 per square foot can be taken for measures affecting any one of three building systems: the building envelope, lighting, or heating and cooling systems.  These tax deductions are available for systems “placed in service” from January 1, 2006 through December 31, 2013.  Professional SPF contractors serving the insulation and roofing components of commercial buildings can benefit from these tax deduction provisions by reducing the first-cost (investment cost) of SPF insulation and roofing.

STATE Level

SPFA Participates in Massachusetts State-Sponsored SPF Workshop

The workshop, hosted by the Mass. Office of Technical Assistance and Technology, and a variety of state agencies focused upon “Safe Spraying and Intelligent Insulation.” SPFA was central to this gathering, several more of which are planned throughout the state in 2014. The core focus is upon the SPFA Professional Certification Program, performance of SPF, and workplace safe and effective installation practices for the benefit of the state’s construction trade professionals, agency representatives, customers, and others dependent upon the performance of the technology. Other areas covered include state and federal implementation of regulations, and best practices among the industry.

SPFA Testifies at Connecticut Hearing Considering SPF Professional Certification Mandates

In 2013 the state of Connecticut proposed a bill requiring the certification of SPF professionals. On the heels of the SPFA Professional Certification Program rollout, a program compliant with stringent ISO 17024 requirements impacting development and operation, SPFA offered information to the state regarding the SPF industry, various certifications available, and testified before the CT General Law Committee. That testimony is available on the SPFA YouTube page found here.

SPFA Engages Louisiana State Code Council

In 2013 SPFA travelled to Louisiana to discuss unique construction challenges, SPF applicability, codes, and provide education on SPF topics of interest to state regulators, code professionals, and members of the state’s Home Builders’ Association. Education efforts also focused upon quality installation practices, professional certifications, and jobsite health and safety.

SPFA California Members Active in State Rulemaking

Throughout 2010 and 2011 and continuing today, an ad-hoc group of California stakeholder members worked diligently with the California Energy Commission staff to recognize both open and closed cell SPF insulation in the 2013 Building Energy Efficiency Standard (Title 24).  This same group convened in 2013 to support ACC’s Energy Efficient Foam Coalition to oppose AB127, which proposed to eliminate flame retardants in foam plastic insulations, creating a potentially unsafe fire situation for workers and customers.

SPFA Statement on California DTSC Priority Product Announcement

In March 2014 the California Department of Toxic Substance Control announced three priority product areas that the state will focus upon for potential rulemakings, intended to limit or potentially ban the use of those products in the state.  Spray polyurethane foam was identified as one Priority   Product area.  SPFA contends that this decision to include SPF was misguided, an over-reach, and based upon information utilized by DTSC that was less than accurate as presented.  SPFA recognizes that the state is a very important driver for reducing environmental footprints of products and buildings, and increasing building energy efficiency.  Customers from home and commercial building owners to homebuilders and architects demand the use of SPF to reach the ever-increasing energy codes in the state due to its superior product performance.  SPF is a safe product that delivers, and any efforts to limit or ban its use will be a great detriment to the customers in the state, as well as the many small professional businesses that install SPF, and will be met with significant opposition by SPFA.  SPFA initial statement available by clicking HERE.

SPFA continues to engage various state and federal representatives with the goal of educating them upon the industry’s best practices, value of professional certifications, high performance characteristics of SPF, US-based jobs creation for manufacturers and professional contractors, and reciprocally communicating the activities and interests of those representatives to the SPFA membership.

SPFA believes that the path to a healthful, safe, high-quality and performing SPF installation travels through the hands of a knowledgeable, trained, experienced, and ideally PCP-certified professional contractor.